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1410 Duncan Loop S., Suite 5-308 Dunedin, Fl 34698 Ph: 727-565-1785 Fax;: 760-203-0040 roland.ashby.sr@lequipeinc.us L EQUIPE WORLD WIDE INC February 5, 2013 TO WHOM IT MAY CONCERN This narrative is in response to an erroneous posting on a blog called RIPOFF REPORT written by Jay Raja on October 23, 2008. (Attachment A). A number of investors, in November 2007, formed a company by the name of L Equipe Capital Investments 110707 which was owned by L Equipe US, Inc (50%) and 50% by nine (9) other shareholders. The shareholders were the incorporators and they approved all the needed corporate documents and in some cases they even helped write them. (See Exhibit A Shareholder Agreement in Attachment B). I, Roland C. Ashby Sr. was the Treasurer of the newly formed Company. The Corporate Secretary took and and kept minutes in the ordinary course of business. The minutes were created at or about the time of the events they accurately portray. One of the corporate articles was that no one could sell their stock in the corpration until all of the shareholders had first right to purchase the stock. (See Exhibit A Shareholder Agreement Paragraph 7 in Attachment B) On November 29, 2007, Jehanger Raja a/k/a Jay Raja, on behalf of Eastern Equity Partners, LLC ( Eastern Equity ) purchased 49 shares of L Equipe stock. (See Exhibit D in Attachment B) On approximately March 10 th 2008 Mr. Raja sold 24 shares of L Equipe stock for $734,400.00 without notice to the Company using false Company documents to swindle the unsuspecting purchaser. (See Exhibit C Agreement to purchase and sale of shares in Attachment B). He never intended to provide purchasers the proof of their purchase of the 24 shares, as he knew that he could not sell without permission from L Equipe. On July 10, 2008, L'Equipe was served with a Complaint captioned. JD Parker Construction, Inc., et al. v. Eastern Equity Partners, Ltd., ef al.. in the United States District Court, for the District of Colorado, Civil Action No. 08-CV-01392-LTB-MJW. (See Attachment B). The Complaint alleged that Plaintiffs J.D. Parker Construction Company, Inc., Elizabeth S. Landen and Gerald C. Landen as trustees of the Elizabeth S. Landen Trust and the Gerald C. Landen Family Living Trust wired $734.400.00 (from Colorado) to stock. The Complaint further alleges that Jay Raja and Eastern Equity never sold its L'Equipe stock despite receiving the $734,400.00. PDF created with pdffactory trial version www.pdffactory.com

Prior to receiving the Complaint, L'Equipe had no knowledge of the existence of any of the Plaintiffs, Calvin Landen, J.D. Parker or Davis B. Parker. In addition neither Jay Raja, nor any other representative or agent of Eastern Equity presented, or attempted to present, any offer to L'Equipe, L'Equipe 110707-1, or their shareholders before attempting to sell Eastern Equity's shares of L'Equipe 110707-1 stock. Shortly after receiving the Complaint, I contacted Buckley N. Riggs, Esq., who is one of the attorneys for the Plaintiffs. Initially, I spoke with Mr. Riggs to ascertain whether there was some sort of confusion on the Plaintiff s part as to what had occurred because L Equipe and L Equipe 110707-1 were unaware of any attempt of Eastern Equity to sell its Shares of L'Equipe 110707-1 stock. In response, Mr. Riggs provided me receipts showing that Plaintiffs wired $734,400.00 from Colorado to Eastern Equity in Dallas, Texas. I then contacted Mr. Raja to determine what exactly had happened, and heeventually admitted to me that Eastern Equity had received the money represented in the wire transfer receipt which amounts to $734,400.00. Mr. Raja also informed me that he was trying to sell a portion of Eastern Equity's 49 shares of L'Equipe 110707-1 stock to Plaintiffs. Although L'Equipe did nothing wrong and had no liability to the Plaintiffs, I attempted to help facilitate a settlement for Mr. Raja to return the money but he refused. At that point, our company sent Mr. Raja a breach of contract letter per Exhibit C. On September 25, 2008 L Equipe was dismissed from the Law suit (see Attachment D), which apparently infuriated Mr. Raja. Approximately 90 days later Mr. Raja sued L Equipe in the state of Texas. L Equipe s lawyers submitted Defendants Special Appearance Challenging Personal Jurisdiction (See Attachment E) and I submitted an affidavit as it related to the case (See Attachment F) and based on these documents the law suit was dismiss on or about February 20, 2011. That is when Mr. Raja wrote the narrative to RIPOFF REPORT. As you can clearly see the narrative he wrote has absolutely nothing to do with truth of the situation. Mr. Raja wrote We are seeking the assistance of any persons or firms who have run into L'Equipe Capital Investments. Our firm, Eastern Equity Partners and our CEO, Jay Raja, have been defrauded of very large sums of money by L'Equipe and we are reaching out to the industry to find any firms or persons who have any experience (positive or negative) in dealing with L'Equipe. The truth is that Mr. Raja is the one who defrauded Elizabeth S. Landen and Gerald C. Landen of $734,400.00. Mr. Raja wrote, L'Equipe presents prospective investors with a very attractive, risk free, investment opportunity to buy and sell debt securities (trading program). All that is needed is to show proof of funds to the seller of the debt security, and then sell the security to a buyer (pension fund) and make money on the spread. Because investor capital is never supposedly at risk, there is a very high rate of L Equipe World Wide Inc 1410 Duncan Loop S, Suite 5-308 Dunedin, Fl 34698 Ph (727)565-1785 Fax (760)203-0040 E-mail roland.ashby.sr@lequipeinc.us PDF created with pdffactory trial version www.pdffactory.com

return and the transaction is touted as risk free. The truth is that the shareholder Agreement (Attachment B) which Mr. Raja signed does not mention any of what is stated above. Specifically in Para 1.3, it was stated : Venture Business Activity: Shareholder and Corporate officers as participants in the Venture Business understand and agree that the business model is to secure a lease funds provider and funding facility (credit line) against the funds and assets which will be provided by Shareholder. The funding facility will be utilized for entry into and participation in Private Placement Investment Program ( PPIP ), a trade programs or managed buy-sell programs for financial instruments ( Programs ). The majority of the Profits generated from the Programs (if any) may be required to be utilized to fund and support national humanitarian efforts and national industrial, commercial and infrastructure development projects ( Projects ). It is understood and agreed that the beneficiary of the majority of the Profits will be determined by the shareholders jointly or individually Mr. Raja wrote, This group has been committing financial fraud under various entity names and schemes for over a decade now. The truth is that this was only financial transaction that we were involved in and there has not been any other complaints filed with any agency or the other site on the Internet. In summary, Mr. Raja is the guilty party, not L Equipe. Sincerely, Roland C. Ashby Sr., President Note: Some of the documents attached with this letter are not the executed documents because the executed documents are in achieve with our legal counsel, Robert D. Williams, P.C. L Equipe World Wide Inc 1410 Duncan Loop S, Suite 5-308 Dunedin, Fl 34698 Ph (727)565-1785 Fax (760)203-0040 E-mail roland.ashby.sr@lequipeinc.us PDF created with pdffactory trial version www.pdffactory.com

Attachment A JAY RAJA S POSTING ON RIPOFF REPORT We are seeking the assistance of any persons or firms who have run into L'Equipe Capital Investments. Our firm, Eastern Equity Partners Partners and our CEO, Jay Raja, have been defrauded of very large sums of money by L'Equipe and we are reaching out to the industry to find any firms or persons who have any experience (positive or negative) in dealing with L'Equipe. L'Equipe presents prospective investors with a very attractive, risk free, investment opportunity to buy and sell debt securities (trading program). All that is needed is to show proof of funds to the seller of the debt security, and then sell the security to a buyer (pension fund) and make money on the spread. Because investor capital is never supposedly at risk, there is a very high rate of return and the transaction is touted as risk free. This group has been committing financial fraud under various enitity names and schemes for over a decade now. Under the surface (corporate veil) the same names appear. We are not ready to disclose their individual identities on the internet (yet) but would be very interested in working with anybody who has dealt with them. Another recent entity names is Capital 02. Ref: http://www.ripoffreport.com/investment-brokers/l-equipe-capital-inv/l-equipe-capitalinvestments-l-f76a7.htm PDF created with pdffactory trial version www.pdffactory.com

ATTACHMENT E Dallas County 116 th Judicial District Court 116 th Judicial District Clerk 600 Commerce Street, Box 640 Dallas, TX 75202 Re: Eastern Equity Partners, LLC v. L'Equipe US, Inc, L'Equipe Capital Investments 110707-1, Inc., Roland C. Ashby, Sr., Robert B. Clark-Ashby, Thomas Burgos, and 02 Capital, Inc. Dear Clerk: X Please find enclosed for filing in the above captioned cause: DEFENDANTS L EQUIPE US, INC, L EQUIPE CAPITAL INVESTMENTS 110707-1, INC., ROLAND C. ASHBY, SR., ROBERT B. CLARK-ASHBY, THOMAS BURGOS, AND 02 CAPTIAL, INC. S SPECIAL APPEARANCE CHALLENGING PERSONAL JURISDICTION (2 copies) X Please fill out the attached fiat setting this Motion for hearing, and return to us a conformed copy of the Motion and fiat in the enclosed pre-paid envelope Sincerely, Patrick Clerkin PDF created with pdffactory trial version www.pdffactory.com

Cause No. 08-9755 EASTERN EQUITY PARTNERS, LLC, Plaintiff, vs. L EQUIPE US, INC., L EQUIPE CAPITAL INVESTMENTS 110707-1, INC., ROLAND C. ASHBY, SR., ROBERT B. CLARK-ASHBY, THOMAS BURGOS, AND 02 CAPITAL, INC. Defendants IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 116 TH JUDICIAL DISTRICT COURT DEFENDANTS SPECIAL APPEARANCE CHALLENGING PERSONAL JURISDICTION Defendants ask the court to sustain their special appearance and dismiss plaintiff s suit. A. Introduction 1. Plaintiff is Eastern Equity Partners, LLC; Defendants are L Equipe US, Inc., L Equipe Capital Invetstments 110707-1, Inc., Roland C. Ashby. Sr., Robert B. Clark- Ashby, Thomas Burgos, and 02 Capital, Inc. 2. Plaintiff sued Defendants for allegations of fraud and breach of contract. B. Facts 3. Defendants are not residents of the State of Texas and have had no purposeful contacts with this state. Defendants are individuals and corporations and do not reside and/or do business in Texas. Defendants reside and/or do business in the State of Florida. 4. Defendants never advertised to, traveled to, or contacted Plaintiff about the subject matter in Plaintiff s Original Petition. While Defendants were in Florida, Plaintiff contacted Defendants about a potential business transaction. At no time did any Defendant travel to Texas to illicit business with Plaintiff. Plaintiff traveled to Florida to sign all agreements and to conduct business associated with the subject matter of this litigation. The only contacts Defendants had with Plaintiff were phone calls made from Florida to Texas, but this was after Plaintiff sought Defendants for potential business agreements. Florida and/or the United States Virgin Islands are the appropriate venues per section 26 of the Shareholder Agreement signed by Plaintiff, Defendants, and other parties which is attached hereto as Exhibit A and incorporated as referenced as if set out in full. 5. Defendants attach the affidavits of Roland C. Ashby, Sr., Roland B. Clark- Ashby, and Thomas Burgos, attached hereto as Exhibits B, C, and D respectively, to this special appearance to establish facts not apparent from the record and incorporates them by reference. DEFENDANTS SPECIAL APPEARANCE Page 1 of 4 PDF created with pdffactory trial version www.pdffactory.com

C. Argument & Authorities 6. Texas courts do not have jurisdiction over a nonresident defendant unless the nonresident defendant has purposefully established minimum contacts with Texas, and the court s exercise of jurisdiction over defendant comports with fair play and substantial justice. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 474-76 (1985); BMC Software Belg. v. Marchand, 83 S.W.3d 789, 795 (Tex. 2002); Guardian Royal Exch. Assur., Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223, 226 (Tex. 1991). No Minimum Contacts 7. Under minimum contacts analysis, Texas courts must determine whether the nonresident defendant has purposefully availed itself of the privilege of conducting activities within Texas. Michiana Easy Livin Country, Inc. v. Holten, 168 S.W.3d 777, 784-85 (Tex. 2005); Guardian Royal, 815 S.W.2d at 226; see CSR Ltd. v. Link, 925 S.W.2d 591, 596 (Tex. 1996). Minimum contacts are not established unless the court finds it has either specific or general jurisdiction over the defendant. See Commonwealth Gen. Corp. v. York, 177 S.W.3d 923, 925 (Tex. 2005); BMC Software, 83 S.W.3d at 795. 8. Texas courts cannot exercise specific jurisdiction over a nonresident defendant unless the nonresident defendant s activities were purposefully directed to Texas, and the litigation resulted from injuries that are alleged to arise out of or relate to those activities. National Indus. Sand Ass n v. Gibson, 897 S.W.2d 769, 774 (Tex. 1995); Schlobohm v. Schapiro, 784 S.W.2d 355, 358 (Tex. 1990); see Helicopteros Nacionales v. Hall, 466 U.S. 408, 414 (1984); BMC Software, 83 S.W.3d at 796. Texas courts do not have specific jurisdiction over defendants because defendants did not purposefully direct their activities to Texas, and plaintiff s cause of action did not arise from or relate to defendants contacts with Texas. Rather, plaintiff s cause of action arose from Plaintiff s dealings with Defendants in Florida. Plaintiff initiated contacts with Defendants in Florida. Plaintiff traveled to Florida to sign all transactions related to the subject matter of this litigation. Plaintiff also agreed that the State of Florida and/or the United States Virgin Islands would be the appropriate venue if a dispute between the parties arose, as is evidence by the Shareholder Agreement attached hereto as Exhibit A. 9. Texas courts cannot exercise general jurisdiction over a nonresident defendant unless the nonresident defendant has continuous and systematic contacts with Texas. BMC Software, 83 S.W.3d at 796; Guardian Royal, 815 S.W.2d at 230; see Helicopteros Nacionales v. Hall, 466 U.S. 408, 415-16 (1984). Texas courts do not have general jurisdiction over Defendants because Defendants have not had continuous or systematic contacts with Texas. The Defendants had no substantial or even limited contact with Texas. The Defendants did not travel to Texas, have no place of business or residences in the State of Texas, nor has any Defendant taken any action that would put Defendants on notice that Defendants would be subject to the call of a Texas court. The only contact Defendants had with Texas were phone calls to Plaintiff after Plaintiff initiated the potential business transaction. These phone calls from Defendants are DEFENDANTS SPECIAL APPEARANCE Page 2 of 4 PDF created with pdffactory trial version www.pdffactory.com

neither systematic nor continuous under any interpretation of current Texas case law on this subject, or even by any stretch of the imagination. 10. Texas courts cannot exercise general jurisdiction over a nonresident defendant on the mere allegation of a conspiracy. National Indus. Sand Ass n v. Gibson, 897 S.W.2d 769, 774-76 (Tex.1995). Plaintiff, in its Original Petition, states that the Court has jurisdiction over Defendants as a result of an alleged conspiracy among the defendants. Texas courts do not allow an allegation of conspiracy between a nonresident and a Texas corporation to confer personal jurisdiction. Id. Fair Play & Due Process 11. This court s assumption of jurisdiction over the defendants and their property will offend traditional notions of fair play and substantial justice and will be inconsistent with the constitutional requirements of due process. See International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945); Guardian Royal, 815 S.W.2d at 231. The court should decline to exercise jurisdiction over defendants because first, the burden on defendants would be overwhelming. Defendants conduct no business in Texas, own no property in Texas, do not live in Texas, do not travel to Texas for business, nor do they advertise or solicit business in Texas. Second, the interest of Texas in adjudicating the dispute is non-existent to minimal at best. The Plaintiff s suit is based on disagreements it has with Defendants who live in Florida and with third parties that reside in Colorado. Plaintiff s disputes arose out of an agreement governed by Florida law and out of Plaintiff s contacts with businesses and defendants in Florida. Third, the Plaintiff s interest in obtaining convenient and effective relief can be obtained in Florida, as agreed to by Plaintiff when it entered into the Shareholders Agreement. Fourth, the interstate judicial system s interest in obtaining the most efficient resolution of controversies can be obtained in Florida, as Florida is the law that governs this suit, where the vast majority of the parties reside, and where most actions complained of by Plaintiff took place. Fifth, the shared interest of the states in furthering fundamental social policies demands that Texas allow Florida to interpret and govern Florida law, and business transactions that occurred in Florida. Guardian Royal, 815 S.W.2d at 231. D. Conclusion 12. Defendants do not have the minimum contacts with the State of Texas to justify a Texas court s assumption of jurisdiction. If this court assumes jurisdiction over Defendants, it will offend traditional notions of fair play and substantial justice. E. Prayer 13. For these reasons, Defendants ask the court to set their special appearance for hearing and, after the hearing, sustain Defendants special appearance and enter a final judgment dismissing plaintiff s cause of action. DEFENDANTS SPECIAL APPEARANCE Page 3 of 4 PDF created with pdffactory trial version www.pdffactory.com

The undersigned certifies compliance with Rule 21 and Rule 21(a), Texas Rules of Civil Procedure on February 5, 2013. Respectfully submitted, CLERKIN & SINCLAIR, LLP By: Patrick Clerkin / SBN: 24040702 202 N. Allen Dr Suite F Allen, TX 75013 214-383-9088 [office] 214-383-5890 [fax] DEFENDANTS SPECIAL APPEARANCE Page 4 of 4 PDF created with pdffactory trial version www.pdffactory.com

ATTACHMENT F Cause No. 08-9755 EASTERN EQUITY PARTNERS, LLC, Plaintiff, vs. L EQUIPE US, INC., L EQUIPE CAPITAL INVESTMENTS 110707-1, INC., ROLAND C. ASHBY, SR., ROBERT B. CLARK-ASHBY, THOMAS BURGOS, AND 02 CAPITAL, INC. Defendants IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 116 TH JUDICIAL DISTRICT COURT AFFIDAVIT OF ROLAND C. ASHBY, SR. Before me, the undersigned authority, personally appeared Roland C. Ashby, Sr., a person whose identity is known to me, who, being by me duly sworn, deposed as follows: My name is Roland C. Ashby, Sr.. I am capable of making this affidavit. I am over the age of 21 and I am of sound mind. The facts stated within this affidavit filed in support of Defendants Special Appearance Challenging Personal Jurisdiction are within my personal knowledge and are true and correct. The following facts are known to me: 1. I am treasurer of L'Equipe US, Inc. and L'Equipe Capital Investments 110707-1, Inc., ( L Equipe). I am presindent and treasurer of 02 Capital, Inc. ( 02 Capital ). As such, I am familiar with the business records maintained by L Equipe US, Inc., L Equipe, and 02 Capital, which are kept in the ordinary course of business and were created at or about the time of the events they accurately portray. 2. On November 29, 2007, Jehanger Raja a/k/a Jay Raja, on behalf of Eastern Equity Parnters, LLC ( Eastern Equity ) purchased 49 shares of L Equipe stock. A copy of the Shareholder Agreement is attached as Exhibit A to Defendants Special Appearance Challenging Personal Jurisdiction. 3. In September of 2008 myself, L Equipe US, Inc., L Equipe, and 02 Capital were given documents showing a lawsuit captioned, Eastern Equity Partners, LLC v. L Equipe US, Inc., L Equipe Capital Invesments 110707-1, Inc., Roland C. Ashby, Sr., Robert B. Clark-Ashby, Thomas Burgos, and 02 Captial, Inc., was filed in the 116 th Judicial District Court, Dallas County, Texas, Cause Number: 08-9755. AFFIDAVIT OF ROLAND C. ASHBY, SR. Page 1 of 3 PDF created with pdffactory trial version www.pdffactory.com

ATTACHMENT F 4. The petition alleges causes of action for Breach of Contract and Fraud arising out of Plaintiff s contact with Defendants and Plaintiff s investment in L Equipe. The petition further alleges that Roland C. Ashby, Robert Clark- Ashby and Thomas Burgos contacted Plaintiff regarding investment L Equipe. 5. At no time did Roland C. Ashby, L Equipe, L Equipe US, Inc., or 02 Capital ever initiate communication with Plaintiff regarding investment in L Equipe or L Equipe US Inc. After Plaintiff inquired about a possible investment in L Equipe, then Roland C. Ashby began discussing Plaintiff s possible investment opportunities by telephone or personal contact in Florida. 6. At no time did Roland C. Ashby, L Equipe, L Equipe US, Inc., or 02 Capital ever travel to Texas to discuss Plaintiff s investment in L Equipe. At no time did Roland C. Ashby, L Equipe, L Equipe US, Inc., or 02 Capital advertise or seek investment from individuals and/or corporations in the State of Texas. 7. The only contacts with Texas by Roland C. Ashby, L Equipe, L Equipe US, Inc., or 02 Capital were phone calls from Roland C. Ashby to Jehanger Raja a/k/a Jay Raja to discuss Plaintiff s possible investment in L Equipe. 8. Jehanger Raja a/k/a Jay Raja, on behalf of Plaintiff, traveled to Florida to sign the Shareholder Agreement. 9. Roland C. Ashby, L Equipe, L Equipe US, Inc., and 02 Capital have no businesses in Texas, do not own property in Texas, do not live in Texas, do not travel to Texas for business, nor do they advertise or solicit business in Texas. 10. Section 26 of the Shareholder Agreement, attached as Exhibit A to Defendants Special Appearance Challenging Personal Jurisdiction, requires that any dispute involving the Shareholder Agreement be governed by the laws of the State of Florida. 11. Section 26 of the Shareholder Agreement, attached as Exhibit A to Defendants Special Appearance Challenging Personal Jurisdiction, requires that all disputes arising out of or related to the Shareholder Agreement are to be heard in the courts of the Unites States Virgin Islands. 12. Performance of the Shareholder Agreement never occurred inside the State of Texas. 13. I am not a resident of Texas. AFFIDAVIT OF ROLAND C. ASHBY, SR. Page 2 of 3 PDF created with pdffactory trial version www.pdffactory.com

14. I am a resident of Florida. ATTACHMENT F 15. L'Equipe US, Inc, L'Equipe Capital Investments 110707-1, Inc., and 02 Capital, Inc. are all Florida corporations. These corporations do not operate in Texas, do do not have any offices located in Texas, nor do they own any property or conduct business in Texas on a regular basis. Further Affiant saith not. Roland C. Ashby, Sr., Affiant SUBSCRIBED AND SWORN TO this. My commission expires: Notary Public in and for the State of Florida AFFIDAVIT OF ROLAND C. ASHBY, SR. Page 3 of 3 PDF created with pdffactory trial version www.pdffactory.com